Michael A. Appel 
Late last year, California Governor Gavin Newsom received praise from environmentalists when he announced new rules that require 3,200 feet of buffer space between new oil wells and homes, schools, businesses and healthcare facilities. The state agency that approves the construction of wells endorsed a view long championed by environmental justice advocates – final that living near wells results in poor health, including perinatal and respiratory damage.
But a loophole in the rules could still put hundreds of communities at risk from new wells — even if the state doesn’t consider them new.
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The rules currently under consideration define a new well as “new drilling that involves the installation of surface casing where none previously existed”. This would not prevent operators from restarting unused wells statewide, even if they are within the 3,200 foot setback zone. In some cases, the wells may be so old that few residents living nearby can remember a time when they were active.
About an hour’s drive east of San Francisco, in Contra Costa County between the towns of Antioch and Brentwood, an old oil well that was active at the turn of the last century is back in production thanks directional drilling, a more recent technique in which wells can draw oil both horizontally and vertically. There are many more houses and other developments nearby than half a century ago.
The California Geologic Energy Management Division (CalGEM) enabled an oil company to revive the well pad of a large ranch in the area by installing new directional wells. The company, co-owned by Reabold California and the savage Bob Nunn, has three wells producing about 300 barrels of oil per day and an equal amount of waste water that produces oil. Once pumped, the site’s equipment separates the oil and gas from the water.
Nunn, who has a significant local presence and has drilled in the area for 30 years, said early operators of the field left behind about 40% of its recoverable oil. Last year, he and his partners also asked to turn a clogged, abandoned gas well into an injection well to dispose of waste water produced far below the Earth’s surface; it is still under review by CalGEM.
The wells have raised concerns about the health and safety of residents, and a local environmental group, Sunflower Allianceclaims they are within half a mile of homes, a hospital and a high school, in addition to several proposed residential developments.
“Any operator proposing to reactivate an inactive well in the 3,200 area would be required to install vapor recovery systems and other mitigation measures to protect those who work and live near the well.”
~ Jacob Roper, spokesperson for CalGEM
Sunflower Alliance member Charles Davidson used a mobile Aeris Mira Pico leak detection system to detect high levels of methane and ethane emanating from the well site, in addition to toxic volatile organic compounds. Bay Area Air Quality Management District investigators found ‘fugitive leaks’ but said they did not exceed regulatory limits, although it issued a notice of violation because the operator was pumping oil without a BAAQMD permit.
Ethane is a greenhouse gas but dissipates within months in the atmosphere, while methane is an extremely potent global warming gas with a 12 year atmospheric life.
In his defense, Nunn said regulatory agencies have allowed oil drilling to continue, and he argues that California-produced oil is better for the environment and the transition from fossil fuels than imported oil — although oil produced from the Brentwood field is carbon intensive. assess bigger much of the oil imported into the state. He acknowledges that the well pad is near homes, but denies that it negatively impacts residents.
CalGEM determined that the new oil production wells and the repurposed well for wastewater injection were exempt from environmental reviews that could have assessed air quality impacts. The Sunflower Alliance is to chase CalGEM and the operator of the well, arguing that the wells should have undergone these examinations. “Any operator proposing to reactivate an inactive well in the 3,200 area would be required to install vapor recovery systems and other mitigation measures to protect those who work and live near the well,” a gatekeeper said. -say CalGEM.
But the bigger implication, which likely won’t be argued in court, is that unused wells and well pads may well be revived statewide in the future — just as California finalizes a rollback of 3,200 feet on new drills and pushing for a wider transition away from fossil fuels.
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Shoshana Wechsler, activist with Sunflower Alliance, calls them “zombie sinks” because they come back online with little public scrutiny or notice. She fears that other unused wells in the Brentwood oilfield could be revived in the future.
CalGEM’s proposed rollback rule “simply leaves the backdoor open to massive reworking of old wells,” Wechsler said. “The norm is to give with one hand and take away with the other.”
CalGEM does not appear to specifically track the number of unused wells located near sensitive receptors, such as homes and schools, or how many have been or have the potential to be reactivated. A 2018 report commissioned by the division found 5,540 wells that are orphaned or likely to become orphaned in the near future, and there could be tens of thousands more unused wells depending on how you count them.
According to an analysis by FracTracker, which used data available on CalGEM website, there are 12,491 unused wells statewide that are within the 3,200-foot setback zone. More than 3,000 are in Los Angeles County alone, while there are 2,831 in Kern County and more than 800 each in Orange and Ventura counties; Contra Costa County has 15.
While Nunn says he has no plans to revive any more wells in the Brentwood area, he says state oil operators are reviving old wells “all the time.” Many remain operational but are abandoned due to a drop in the price of oil or gas, ready to come back to life when oil or gas becomes profitable again.
“It’s literally as easy as flipping a switch,” Nunn said, “as long as all the bottom mechanisms are still in place.” If the well has been inactive for a long time, CalGEM might issue some requirements, such as cement reinforcement around the casing, but a full environmental review might be less likely.
“An agency that takes its responsibilities to the public and the environment seriously would do a new environmental review for what is, for all intents and purposes, a new well and a new project.”
~ Hollin Kretzmann, Senior Counsel, Center for Biological Diversity
Yet older casings also have a greater potential for failure, according to Kyle Ferrar, western program coordinator for the FracTracker Alliance, who studies the socioeconomic geography of wells in California.
“Aging well sites that have been around for a long time have a much higher rate of casing failures and a higher level of groundwater contamination than if you plug them up,” he said.
Nunn says the idle well he’s trying to turn into an injection well for produced wastewater will require him to change the downhole configuration of the well, since liquid is now being pumped down instead of up. high. The water would be pumped up to 4,000 feet below the surface, well below shallow groundwater reserves – although the injection is linked to groundwater contamination.
In a project approval letter for the injection well, CalGEM said the original well was approved before California’s 50-year-old passed environmental law and therefore eligible for an exemption. Sunflower Alliance rejected that finding in court, arguing that the injection well was considered a “new use, requiring new permits” and should have been reviewed.
The operators intend to inject sewage into an aquifer formation beneath the Mokelumne River, for which the original operator of the well received a federal EPA pollution exemption in 1982.
“An agency that takes its responsibilities to the public and the environment seriously would do a new environmental review for what is, for all intents and purposes, a new well and a new project,” said Hollin Kretzmann, senior counsel at the Center for Biological. Diversity, which is not involved in the lawsuit.
And if CalGEM continues to approve repurposed unused wells as new wells even if they’re within 3,200 feet of sensitive receptors, it would give oil operators a “major loophole,” Ferrar says.
“It would be an opportunity to take advantage of the rules by re-drilling wells.”
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